UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`CARDIOCOM, LLC
`Petitioner
`v.
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`Patent Owner
`_____________________
`CASE IPR2013-00468
`Patent No. 7,516,192
`_____________________
`
`PATENT OWNER’S OPPOSITION TO PETITIONER’S
`MOTION TO EXCLUDE EVIDENCE
`
`
`_____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`CARDIOCOM, LLC
`Petitioner
`v.
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`Patent Owner
`_____________________
`CASE IPR2013-00468
`Patent No. 7,516,192
`_____________________
`
`PATENT OWNER’S OPPOSITION TO PETITIONER’S
`MOTION TO EXCLUDE EVIDENCE
`
`
`
`Patent Owner Robert Bosch Healthcare Systems, Inc. (“Bosch”) hereby
`
`opposes Petitioner Cardiocom, LLC’s (“Cardiocom”) Motion to Exclude Evidence
`
`(Paper 57, “Mot.”).
`
`I.
`
`INTRODUCTION
`
`Through its motion, Petitioner Cardiocom seeks to deprive the Board of
`
`secondary considerations evidence that plays a “critical role in the obviousness
`
`analysis.” Leo Pharm. Prods., Ltd. v. Rea, 726 F.3d 1346, 1358 (Fed. Cir. 2013).
`
`Despite admitting that there was a long-felt need for the claimed inventions of U.S.
`
`Patent No. 7,516,192 (“the ’192 patent”) in deposition, Cardiocom’s expert has
`
`failed to affirmatively identify any secondary considerations evidence
`
`demonstrating that the claims of the ’192 patent are obvious. Rather, Cardiocom
`
`asks the Board to exclude the substantial evidence of secondary considerations that
`
`Bosch and Dr. David have submitted. Notably, Cardiocom does not challenge the
`
`reliability and authenticity of the underlying evidence. Instead, Cardiocom raises
`
`several technical arguments that are meritless as a matter of law.
`
`First, Cardiocom seeks to exclude Dr. David’s opinions on secondary
`
`considerations, premising its argument on the untenable position that secondary
`
`considerations evidence requires an “element-by-element” claim chart analysis.
`
`With no Federal Circuit law requiring such an analysis—and certainly none cited
`
`by Cardiocom—there is no basis for Cardiocom’s requested relief. Moreover,
`
`-1 -
`
`
`
`Cardiocom and Dr. Stone have not identified a single element of the ’192 patent
`
`claims that is purportedly not related to the secondary considerations evidence.
`
`Second, Cardiocom moves to exclude Bosch’s secondary considerations
`
`evidence as allegedly inadmissible hearsay. Cardiocom is wrong. The challenged
`
`evidence is not hearsay. See Hynix Semiconductor Inc. v. Rambus Inc., No. C-00-
`
`20905 RMW, 2009 WL 112834, at *14 (N.D. Cal. Jan. 16, 2009), aff’d, 645 F.3d
`
`1336 (Fed. Cir. 2011). And, even if it were, Dr. David is entitled as an expert to
`
`rely on hearsay evidence to form his opinions.
`
`II.
`
`STATEMENT OF FACTS
`
`Cardiocom submitted its petition in this proceeding on July 24, 2013,
`
`accompanied by Dr. Stone’s original declaration. Paper 1; Ex. 1008. Neither the
`
`petition nor Dr. Stone’s declaration contained any discussion of secondary
`
`considerations of non-obviousness. See generally id. And Dr. Stone has
`
`confirmed on numerous occasions that he did not consider any such evidence
`
`before concluding that the claims of the ’192 patent were obvious:
`
`Q. So you made up your mind that the claims of the ’420, ’186 and
`’192 patents were invalid as obvious before you considered any
`evidence of secondary considerations?
`[A.] That’s -- that pretty well states the case.
`
`Ex. 2069, 784:15-21; see also id. 783:1-15. In fact, Dr. Stone even testified that,
`
`had he considered such evidence, his opinions on invalidity may ultimately have
`
`-2 -
`
`
`
`come out the other way. Ex. 2009, 258:6-19.
`
`In response to the petition, Bosch submitted the declaration of Dr. David,
`
`wherein he considered and analyzed numerous pieces of secondary considerations
`
`evidence demonstrating the non-obviousness of the ’192 patent. Dr. David
`
`testified as to the existence of at least the following commercial secondary
`
`considerations for the ’192 patent: (1) the invention’s commercial success;
`
`(2) long-felt but unresolved needs; (3) praise by others; (4) teaching away by
`
`others; and (5) copying of the inventions by others. See Ex. 2007 ¶¶ 70-110; see
`
`also Exs. 2010-2057.
`
`Dr. David testified that a nexus exists between the claims of the ’192 patent
`
`and the secondary considerations evidence, such as commercial success. See, e.g.,
`
`Ex. 2007 ¶¶ 73, 88-91, 94-96, 107-110. By way of example, Dr. David testified
`
`that the “substantial, long lasting commercial success” of Bosch’s products were
`
`linked to the scripting features that are “related to the inventions of the ’192
`
`patent.” Id. ¶ 88. Dr. David similarly testified that the VA requirements that were
`
`copied from Bosch’s Health Buddy product were “driven by the scripting features
`
`of the Bosch ’192 patent.” Id. ¶ 107.
`
`In reply, Cardiocom and Dr. Stone did not provide any contrary evidence of
`
`secondary considerations. Paper 52; Ex. 1022. In fact, Dr. Stone admitted over
`
`and over again that there existed secondary considerations of non-obviousness,
`
`-3 -
`
`
`
`including long-felt need and demand. See, e.g., Ex. 2009, 27:1-9, 34:14-35:1,
`
`49:17-20, 59:22-60:1, 76:18-77:5, 90:21-91:24, 103:4-6, 438:22-439:3. Rather
`
`than rebutting this evidence of non-obviousness, Cardiocom and Dr. Stone chose
`
`only to criticize Dr. David’s opinions and evidence, faulting Dr. David for not
`
`conducting an “element-by-element” claim analysis for the secondary
`
`considerations evidence. Mot., 4; Ex. 1022 ¶ 63; Ex. 2069, 792:18-793:9. As Dr.
`
`Stone admitted at deposition, however, Cardiocom’s “element-by-element” test is
`
`cut out of whole cloth as it has no basis in the case law. See Ex. 2069, 795:2-21.
`
`III. ARGUMENT
`
`“Objective evidence of nonobviousness is an important component of the
`
`obviousness inquiry because ‘evidence of secondary considerations may often be
`
`the most probative and cogent evidence in the record. It may often establish that
`
`an invention appearing to have been obvious in light of the prior art was not.’”
`
`Transocean Offshore Deepwater Drilling, Inc. v. Maersk Drilling USA, Inc.,
`
`699 F.3d 1340, 1349 (Fed. Cir. 2012) (citation omitted). Where properly
`
`presented, evidence of secondary considerations must be considered. Plantronics,
`
`Inc. v. Aliph, Inc., 724 F.3d 1343, 1355 (Fed. Cir. 2013).
`
`Cardiocom bears the burden of demonstrating obviousness, including the
`
`burden of presenting secondary evidence supporting its non-obviousness case in its
`
`petition. Gnosis S.P.A. v. South Alabama Med. Sci. Found., Case IPR2013-00116,
`
`-4 -
`
`
`
`Paper 61, at 2-3 (P.T.A.B. Mar. 12, 2014) (“[T]he secondary considerations
`
`evidence is part of the body of evidence from which Petitioners must establish that
`
`a preponderance emerges, in order to prove unpatentability of the patented
`
`claims.”). Cardiocom admittedly elected not to present any secondary
`
`considerations evidence in its petition. See Ex. 2069, 784:15-21. Having failed to
`
`even try to carry its burden with respect to secondary considerations, Cardiocom
`
`now invites error by asking the Board to ignore the evidence of secondary
`
`considerations presented by Bosch and thus skip a necessary step in the
`
`obviousness analysis.
`
`A.
`
`Cardiocom Has Fundamentally Misstated the Secondary
`Considerations Analysis.
`
`Contrary to Cardiocom’s assertions, a prima facie case supporting nexus
`
`between secondary considerations evidence and patent claims requires simply that
`
`“the patentee shows both that there is commercial success, and that the thing
`
`(product or method) that is commercially successful is the invention disclosed and
`
`claimed in the patent.” Demaco Corp. v. F. Von Langsdorff Licensing, Ltd., 851
`
`F.2d 1387, 1392 (Fed. Cir. 1988). “A requirement for proof of the negative of all
`
`imaginable contributing factors would be unfairly burdensome, and contrary to the
`
`ordinary rules of evidence.” Id. at 1394. That prima facie test was met in Demaco,
`
`through evidence of the admitted success of the patented invention. Id. Dr. Stone
`
`does not dispute that the Health Buddy product practiced the claims of the ‘192
`
`-5 -
`
`
`
`Patent.
`
`Once the prima facie test is met, it falls to the patent challenger (Cardiocom)
`
`to “adduce evidence to show that the commercial success was due to extraneous
`
`factors other than the patented invention, such as advertising, superior
`
`workmanship, etc.” Id. at 1393. At bottom, Cardiocom’s motion to exclude fails
`
`because it seeks to foist on Bosch a burden that Cardiocom has borne all along—to
`
`“adduce evidence” (through an “element-by-element” analysis or otherwise)
`
`demonstrating that the commercial success and other secondary considerations
`
`factors identified by Dr. David were due to something other than the claimed
`
`inventions of the ’192 patent. Cardiocom has never “adduce[d]” any such
`
`evidence and therefore its criticisms of Dr. David ring hollow.
`
`B.
`
`Dr. David Established a Sufficient Nexus Between the Secondary
`Considerations Evidence and the Claimed Invention.
`
`There is no dispute that evidence of secondary considerations must be tied to
`
`the claimed inventions of the ’192 patent.1 In re GPAC Inc., 57 F.3d 1573, 1580
`
`1 Bosch has also provided evidence of secondary considerations in related
`
`proceedings concerning U.S. Patent Nos. 7,840,420 and 7,921,186. While there is
`
`overlap in the exhibits of secondary considerations for the ’192, ’420 and ’186
`
`patents, Dr. David provides testimony in each proceeding that ties the evidence to
`
`the particular features claimed in the patent at issue in the proceeding.
`
`-6 -
`
`
`
`(Fed. Cir. 1995). But, in moving to exclude, Cardiocom seeks to impose on Bosch
`
`and Dr. David a greater burden of demonstrating sufficient nexus than has ever
`
`been required by the Federal Circuit, i.e., the comparison of secondary
`
`considerations evidence to the ’192 patent claims on an “element-by-element”
`
`basis. See, e.g., Mot., 4; Ex. 1022 ¶ 63. Notably, neither Cardiocom nor Dr. Stone
`
`cite a single case to support this supposed test. Indeed, if Cardiocom’s “element-
`
`by-element” test were accepted, the use of secondary considerations evidence in
`
`any patent case would effectively be eliminated, as articles, marketing materials,
`
`and the like rarely—if ever—describe the features claimed in patents on an
`
`“element-by-element” basis.
`
`Cardiocom’s arguments to the contrary, Dr. David has provided testimony
`
`establishing a sufficient nexus between the secondary considerations evidence he
`
`considered and the claimed inventions of the ’192 patent. See Section II, supra;
`
`see also Ex. 2007 ¶¶ 73, 88-91, 94-96, 107-110. Moreover, in addition to Dr.
`
`David’s supporting testimony, many of the exhibits of secondary considerations
`
`specifically mention the scripting features that are claimed in the ’192 patent. E.g.,
`
`Ex. 2020 (“Care Composer allows the service’s users to design or modify protocols
`
`and assists them in defining patient health status data and designing disease-
`
`specific messages.”); Ex. 2023 (“Every day the Health Buddy asks patients a series
`
`of questions about their weight, blood pressure, medication and specific aspects of
`
`-7 -
`
`
`
`their conditions.”); Ex. 2055 (citing VA staff testimony about working with Health
`
`Hero “to develop targeted questionnaires for patients with diabetes, heart disease,
`
`and other chronic disorders”).
`
`Dr. Stone himself even testified that there was a long-felt need for the
`
`claimed inventions of the ’192 patent. See Ex. 2069, 835:23-836:7, 1302:24-
`
`1303:19; Ex. 2009, 27:1-9, 34:14-35:1, 49:17-20, 59:22-60:1, 76:18-77:5, 90:21-
`
`91:24, 103:4-6, 438:22-439:3. The totality of this evidence provides a more than
`
`sufficient nexus to the claimed inventions, and thus clearly distinguishes the cases
`
`that Cardiocom relies upon. See, e.g., Ormco Corp. v. Align Tech., Inc., 463 F.3d
`
`1299, 1312 (Fed. Cir. 2006) (patentee’s witnesses “testified that commercial
`
`success was due to unclaimed or non-novel features of the device”); In re Paulsen,
`
`30 F.3d 1475, 1482 (Fed. Cir. 1994) (finding insufficient evidence to establish
`
`commercial success was not due to other extraneous factors).
`
`C.
`
`Cardiocom’s Arguments Are Legally Unsound and Ignore the
`Evidence Presented by Bosch and Dr. David.
`
`Cardiocom ignores all of the contrary evidence discussed above and takes an
`
`out-of-context quote from Dr. David’s deposition to suggest that he ignored the
`
`real drivers of the success of the Health Buddy. Mot., 6 (citing David Dep. (Ex.
`
`1041), 161:6-9). This is a gross mischaracterization of Dr. David’s opinions.
`
`Initially, Cardiocom fails to disclose that Dr. David did not even understand the
`
`question from Cardiocom’s attorney that elicited the testimony Cardiocom relies
`
`-8 -
`
`
`
`upon. Ex. 1041, 161:10-17. More importantly, Dr. David actually testified the
`
`opposite of what Cardiocom suggests, stating that “[w]hat was important for my
`
`declaration is that nexus you described yourself relating to claims in the patent.”
`
`Id., 160:25-161:3. Dr. David thus focused on success attributable to the claimed
`
`invention and, having established that the nexus existed, did not attempt to analyze
`
`every other factor that could have also possibly contributed to the success. See
`
`also id., 160:2-18, 172:1-7, 621:3-15. Nor was he required to, as Federal Circuit
`
`law does not require a patent owner to “prove as part of its prima facie case that the
`
`commercial success of the patented invention is not due to factors other than the
`
`patented invention. It is sufficient to show that the commercial success was of the
`
`patented invention itself.” Demaco, 851 F.2d at 1394.
`
`For the same reason, the Board should also reject Cardiocom’s argument
`
`relating to the alleged contribution of the four-button design to the commercial
`
`success of the Health Buddy. Mot., 5. Once Dr. David established a sufficient
`
`nexus to the claimed inventions, he was not required to rebut all imagined
`
`contributing factors. Demaco, 851 F.2d at 1394. Moreover, Cardiocom’s
`
`contention that the years of praise, success, and long-felt need for the Health
`
`Buddy is attributable solely to the four-button design is absurd. Indeed, the
`
`absurdity of the claim is confirmed by the fact that Cardiocom has not come forth
`
`with a single shred of independent evidence—articles, newscasts, webpages, or any
`
`-9 -
`
`
`
`other objective evidence—tying the commercial success of the Health Buddy to the
`
`four-button design. Instead, Cardiocom relies only on attorney argument,
`
`supplemented with Dr. Stone’s declaration parroting those arguments without any
`
`evidentiary support. See Paper 52, 4-5; Ex. 1022 ¶ 64. But as the Federal Circuit
`
`has stated, such “‘argument’ and ‘conjecture’ are insufficient” to rebut evidence of
`
`secondary considerations. Demaco, 851 F.2d at 1393 (quoting Rosemount, Inc. v.
`
`Beckman Instruments, Inc., 727 F.2d 1540, 1546 (Fed. Cir. 1984)).
`
`Cardiocom separately argues that Dr. David’s analysis of the commercial
`
`success of Bosch’s Health Buddy was insufficient because there is no evidence
`
`Health Buddy ever made a profit. See Mot., 6-7. Again, however, Cardiocom is
`
`fabricating legal standards, because a “profitability analysis” is not an actual legal
`
`requirement for assessing secondary considerations evidence.2 Notably,
`
`Cardiocom never presented evidence demonstrating that Bosch was unprofitable,
`
`2 In the single case Cardiocom cites, the district court did not even dismiss the
`
`evidence of commercial success based on whether the evidence sufficiently
`
`demonstrated profitability, as Cardiocom contends; rather, the evidence was
`
`dismissed because there was no nexus between the success and the claimed
`
`invention. Cable Elec. Products, Inc. v. Genmark, Inc., 770 F.2d 1015, 1027 (Fed.
`
`Cir. 1985), overruled on other grounds by Midwest Indus., Inc. v. Karavan
`
`Trailers, Inc., 175 F.3d 1356 (Fed. Cir. 1999). A nexus has been established here.
`
`-10 -
`
`
`
`and the fact that the Health Hero business has been selling the Health Buddy for at
`
`least the last 15 years belies Cardiocom’s assertion that the product was
`
`commercially unsuccessful. Moreover, Dr. David demonstrated specific examples
`
`of that commercial success, such as through hospitals and pharmacies adopting
`
`usage of the Health Buddy. Ex. 2007 ¶ 79; Exs. 2011-2014. He also cited several
`
`articles regarding substantial sales of the Health Buddy. See, e.g., Ex. 2055 (noting
`
`that the VA had eight pilot projects costing $750,000 each); Ex. 2016 (stating that
`
`Health Hero landed an additional $8 million in new financing for Health Buddy);
`
`Ex. 2010 (noting that the VA awarded a new contract for the Health Buddy in
`
`2011). This testimony and evidence is more than sufficient to demonstrate
`
`commercial success and is unrebutted by any actual evidence adduced by
`
`Cardicom.
`
`At most, Cardiocom’s challenge goes to the sufficiency of the evidence;
`
`such a challenge is not properly brought as an evidentiary objection. See Office
`
`Patent Trial Practice Guide, 77 Fed. Reg. 48755, 48767 (Aug. 14, 2012) (noting
`
`that a motion to exclude “may not be used to challenge the sufficiency of the
`
`evidence to prove a particular fact”).
`
`D.
`
`Dr. David Properly Relied Upon Third-Party Statements to
`Support His Expert Opinions.
`
`Cardiocom also seeks to exclude alleged “third-party hearsay evidence” that
`
`Dr. David relies upon in forming his opinions of non-obviousness. Cardiocom
`
`-11 -
`
`
`
`agrees that, under Federal Rule of Evidence 703, an expert witness such as Dr.
`
`David may rely on hearsay evidence. Mot., 8. Cardiocom nevertheless argues that
`
`Bosch’s secondary considerations evidence should be excluded because (1) Dr.
`
`David’s secondary considerations analysis is fundamentally flawed, and (2) such
`
`evidence is hearsay that should not be admitted as direct evidence of the truth of
`
`the matter asserted. Id.
`
`Cardiocom’s first argument is circular and must be rejected. Earlier in its
`
`motion, Cardiocom argues that Dr. David’s opinions should be excluded as
`
`fundamentally flawed because of the evidence he relies upon. Mot., 6-7.
`
`Cardiocom goes on to argue that the evidence Dr. David relies upon should be
`
`excluded because his opinions are fundamentally flawed. Id., 8. Cardiocom does
`
`not get to assume its conclusion in order to justify its motion to exclude.
`
`Cardiocom’s second hearsay argument must also be rejected for multiple
`
`reasons. First, it fails because it challenges evidence as “hearsay” even though that
`
`evidence is not offered for the truth of the matter asserted. See Fed. R. Evid.
`
`801(c)(2). The proffered evidence is cited in connection with secondary
`
`considerations factors such as praise from others, commercial success, and long-
`
`felt need; these factors turn on public recognition of the claimed inventions, which
`
`is demonstrated by the challenged evidence. Relying on evidence for this purpose
`
`is a legitimate non-hearsay use. See, e.g., Hynix Semiconductor, 2009 WL 112834,
`
`-12 -
`
`
`
`at *14 (“[T]he article does not constitute hearsay because it was admitted not for
`
`its truth, but as a proper secondary consideration of nonobviousness in the form of
`
`praise from others in the industry.”).
`
`For example, Cardiocom complains of the alleged use of hearsay evidence in
`
`Paragraph 88 of Dr. David’s declaration, where Dr. David discusses the
`
`commercial success of the claimed inventions as evidenced by media coverage
`
`about the Health Buddy product. Mot., 7. In providing this opinion, Dr. David
`
`specifically relies on a news article titled “Health Hero Improves Patient Care With
`
`Direct Provider Link.” Ex. 2020. In discussing the article, Dr. David does not rely
`
`on the truth or accuracy of the statements made; rather, he relies on the statements
`
`to demonstrate the secondary consideration of commercial success. Ex. 2007 ¶ 88.
`
`As in the Hynix case, such evidence is not hearsay.3 Similarly, Dr. David relies
`
`upon a VA solicitation (Ex. 2056) not for the truth of its contents, but rather to
`
`3 Moreover, even if the Board entertained Cardiocom’s hearsay argument,
`
`Cardiocom fails to acknowledge that Ex. 2020 is a periodical and thus falls under
`
`the hearsay exception set forth in Fed. R. Evid. 803(18); other exhibits falling
`
`under the periodicals exception include Exs. 2011-2017, 2019, 2021-2027, 2030-
`
`2036, 2050-2055, and 2057. Cardiocom categorically ignores the hearsay
`
`exceptions, making the sweeping (and incorrect) statement that all of Bosch’s
`
`evidence “fall under no exceptions” to the hearsay rule. Mot., 8.
`
`-13 -
`
`
`
`demonstrate an awareness by the market that the VA required others to copy the
`
`scripting features that were first supported by the Health Buddy product. Ex. 2007
`
`¶ 107; see also Ex. 1041, 621:24-625:15.
`
`Aside from not constituting hearsay, the evidence that Cardiocom complains
`
`about all is discussed as bases for Dr. David’s opinions of non-obviousness and is
`
`not simply repeated verbatim for their truth. Bosch therefore does not rely upon
`
`Dr. David’s declaration simply as a conduit to get in otherwise inadmissible
`
`evidence. The case that Cardiocom relies upon is distinguishable on this basis.
`
`See Vondrak v. City of Las Cruces, No. CIV 05-0172 JBLFG, 2007 WL 2219449,
`
`at *3 n.4 (D.N.M. May 14, 2007) (Rule 703 “does not allow the proponent of the
`
`expert testimony to use the expert as a conduit for a party to get in otherwise
`
`inadmissible evidence”).
`
`IV. CONCLUSION
`
`For at least the foregoing reasons, Bosch respectfully requests that the Board
`
`deny Cardiocom’s motion to exclude evidence.
`
`Dated: August 13, 2014
`
`Respectfully submitted,
`
`By:
`
`/Don Daybell/
`Don Daybell, Reg. No. 50,877
`Attorney for Patent Owner Robert Bosch
`Healthcare Systems, Inc.
`
`-14 -
`
`
`
`CERTIFICATION OF SERVICE (37 C.F.R. §§ 42.6(e))
`
`The undersigned hereby certifies that the above-captioned PATENT
`
`OWNER’S OPPOSITION TO PETITIONER’S MOTION TO EXCLUDE
`
`EVIDENCE was served in its entirety on August 13, 2014, upon the following
`
`parties via electronic mail:
`
`Counsel for Petitioner
`
`Daniel W. McDonald
`Andrew J. Lagatta
`Merchant & Gould
`80 South 8th St., Suite 3200
`Minneapolis, MN 55402
`CardiocomIPR@merchantgould.com
`
`By:
`
`/Karen Johnson/
`Karen Johnson
`
`-15 -
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
